Privacy Policy

BitWine has created this privacy policy (“Policy”) in order to disclose our information gathering and dissemination practices for the different functions available by and through the Site and/or Services. This Policy applies to you if you are a user, Advisor or other visitor to the Site or Services made available at BitWine.com and at other third party websites. Users, Advisors and all other visitors to the Site and/or Services are referred to in this policy as “you”. BitWine will not disclose to third parties any personal information obtained from you, except as described or as provided for in the Terms of Service. Any terms not defined herein shall have the definition set forth in the Terms of Service.

This privacy policy has been updated to comply with the EU’s General Data Protection Regulation (GDPR).

By using BitWine’s Site and/or Services, you agree to this Policy. If you do not accept this Policy, you must not use the Site and/or Services.

Personal Information

You may browse the Site and/or Services without providing any personal information. However, the actual use of the Site and/or Services requires registration. When you register you will be asked to give us contact information, such as your name and email address. In addition, in the course of using our Site or Services, you may provide us with other personal information. Your personal information will be used primarily in connection with operating and facilitating the services provided by and through the Site and the Services, including contacting you so that we may provide the service you have requested or respond to your requests for information or customer service. This information may also be used to send you updates regarding our company or to share with you other services or benefits that may be of interest to you.

We do not collect or have access to any user financial information, even though we may request information about yourself and your credit card and/or bank account. That financial information is handled, processed, and stored by a third party payment service (such as PayPal or another third party), which facilitates credit card payments in order to purchase a product through the Site. Currently, the Site and Services use PayPal as its third party payment service, but BitWine may, in its sole discretion, choose another third party payment service for the Site and Services. PayPal takes the privacy of your personal information seriously and will use your information only in accordance with the terms of their privacy policies, available at https://www.paypal.com/us/webapps/mpp/ua/privacy-full

The following is a list of personal information collected by BitWine:

Email address

Login name

Full name

PayPal payer ID

PayPal email address

IP address

Geographic location

Profile photo

Chat transcripts

BitWine messages

Favorite advisors list

Reviews

Forum posts and replies

Information in your customer service inquiries

This information will be stored on third party partner servers (e.g. Amazon Web Services) for as long as your account is active. User data is hosted on servers belonging to third parties with whom we have signed Data Processing Agreements. All third party partners are GDPR-compliant. All communications on BitWine are stored, and are used for analytics purposes, for quality assurance, and to maintain long-term relationships between clients and advisors.

Rights under GDPR

Under certain circumstances, users based in the EU have rights under data protection laws in relation to your personal data, namely:

Access, correction, update, or erasure of your data: You may have the right to request access, correction, update, or erasure in regards to any personal data we hold about you. We will consider your request in accordance with applicable laws.

Restriction of processing your personal data. You may have the right to prevent or restrict processing of your personal data.

Portability of your personal data. You may have the right to request transfer of your personal data to a third party, when technically feasible.

Other Information BitWine Collects

BitWine may collect certain information from visitors of the Site and/or Services, such as Internet addresses and other web log information (such as your web request, Internet Protocol (“IP”) address, browser type, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, and one or more cookies that may uniquely identify your browser). This information is logged for internal use by BitWine, including helping diagnose technical problems and to administer the Site and Services in a manner that allows us to constantly improve the quality of the services provided to you. We may also maintain a record of your IP address, to analyze the use of our online services on an aggregate basis. We may also elect to share such information with advertisers and other third parties. BitWine is the sole owner of information collected on the Site. We reserve the right to screen, copy, transmit and review all communications conducted by or through the Site. We may conduct these activities for technical support purposes and in order to enforce our policies and agreements. At our sole discretion, we may decide to conduct these activities at various times or not at all.

We also may use your information to accomplish the following: (i) perform research and analysis about your use of, or interest in, our products, services, content, products, services or content offered by others; (ii) communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us, other companies or other third parties; (iii) develop and display content and advertising tailored to your interests on our site and other sites, including providing our advertisements to you when you visit other sites; and (iv) perform ad tracking and website or mobile application analytics.

Cookies

BitWine may use “cookies” to monitor visitors browsing our website. Cookies allow the server to store its own information about a user on the user’s own computer. They can be used to customize pages for you based on information you may have provided to our website. Cookies may help us better serve you with information tailored specifically for you and for your return visit to the Site. Cookies are a typical part of web browsing today. Many websites that require you to type a password prior to entering a website use a cookie to facilitate the action. Additionally, many sites that do not require passwords also collect and utilize cookies. You are free to decline our cookies if your browser permits, although doing so may interfere with your use of the Site and Services.

Information Collected By Third Parties

Our website may contain links to other websites. Those websites may be governed by terms and conditions and may have privacy policies that differ from ours. BitWine is not responsible for the privacy practices or the content of these other websites. You should exercise your discretion in disclosing personal information to other users of our Site. We are not responsible for any use of this information by you or others to whom you disclose such information by means of our Site and/or Services. In addition, communications between Advisers and Clients may not be encrypted using standard web encryption technologies, and/or when using third party communication platforms (such as Skype software, services, and/or platform). Third parties may improperly intercept or access transmissions or private communications, and other users may abuse or misuse your information that they collect from the Site. Therefore, although we try to protect your privacy, we cannot promise, and you should not expect, that your personal information or private communications will always remain encrypted and private. By using the Site and/or Services, you agree to use all information collected in connection with the Site and/or Services for lawful purposes and only in connection with your permitted activities in connection with the Site and/or Services.

We use Google AdWords Remarketing to advertise the Site and Services across the Internet. AdWords remarketing will display relevant ads tailored to you based on what parts of the Site and Service you have viewed by placing a cookie on your machine. Google AdWords Remarketing allows BitWine to tailor its marketing to better suit your needs and only display ads that are relevant to you.

How to Opt Out of Remarketing and Advertising: If you do not wish to participate in our Google AdWords Remarketing, you can opt out by visiting Google’s Ads Preferences Manager.

Security

The information you provide to us will be kept in our database. We will use reasonable means to protect the integrity and safety of the database. However, we cannot guarantee that the database will not be improperly accessed by third parties. BitWine relies on professional hosting solutions that use reasonable care in maintaining security measures to protect you and our systems against unauthorized access to, or alteration, disclosure, destruction or loss of personal data hosted on our system.

Password

Your password is the key to your account. Use unique numbers, letters, and special characters and do not disclose your BitWine password to anyone. If you do share your password or your personal information with others, remember that you are responsible for all actions taken in the name of your account. If you lose control of your password, you may lose substantial control over your personal information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately notify BitWine and change your password.

Correcting, Sharing & Updating Your Information

BitWine allows you to view the information you have provided after registration and to correct any inaccuracies or errors that may exist in the data, however it is solely your responsibility to do so. Should you engage in any communication using the Site and/or Services, you bear the sole responsibility as to the substance, character, and nature of the information you provide during any such use. In addition, if you do not wish to furnish any information, then you should not do so.

You understand that if you engage in any form of communication with an Advisor or any user using the chat, email, voice or other communication facilities, functions, or software provided by and through the Site and/or Services, you may voluntarily provide, or otherwise be asked to provide, certain personal information, including without limitation your name and other information requested by an Advisor or otherwise to enable you to participate in the Site and or Services. BitWine may provide areas and functionalities on the Site and Services enabling you to post information about yourself and others and communicate with others,including Advisors. BitWine cannot control who reads your posting or what other users may do with the information you voluntarily post, so BitWine encourages you to exercise discretion and caution with respect to your personal information. BitWine also strongly encourages you to exercise caution and to use reasonable judgment in providing any personal information, including financial information, to any Advisor, and BitWine will not be held responsible for the manner in which any Advisor uses such information.

BitWine may from time to time, maintain transcripts of any such chats, emails and other communications conducted between you and any Advisor or other user using Site and/or Services. In addition BitWine may from time to time, in compliance with applicable law, record and maintain recordings of voice communications between you and any Advisor or other user.

Our Disclosure of Your Information

Your personal information may be disclosed to BitWine affiliates. In addition, we may disclose your personal information to third parties and the performance of the related services, including to service providers who help with our business operations. In addition, we may provide certain information presented to us by Advisors to third parties with whom we do business, and by registering or using the Site as an Advisor you hereby consent to such use of your personal information. We may disclose your personal information to enforce our agreements and policies or respond to claims that information submitted or other content or submissions violates applicable laws or regulations, the rights of others, or to protect anyone’s rights, property, or safety. We also may disclose your information to respond to legal requirements or when we believe in good faith that the disclosure of information is necessary to prevent imminent harm or financial loss or to report suspected illegal activity. We may use our discretion to disclose your information under appropriate confidentiality conditions in connection with merger, acquisition or sale of asset or business activities involving our company or its affiliates. We may disclose non-personally identifying information (including, without limitation, aggregated information) as we believe is reasonable in connection with our business. This information will not identify individual users. Information collected through the Site may be stored and processed in any countries in which we or our service providers maintain facilities, including outside of the European Union. You therefore understand and consent that your information may be transferred outside of the country in which you reside.

Changes to the Policy

BitWine reserves the right to replace, modify or amend this Policy from time to time by posting the replaced, modified, or amended terms on the Site, so we recommend that you review this Policy from time to time. Your use of any Site and/orServices following any change to this Policy shall represent your consent to the new Policy to the fullest extent permitted by law.

General Data Protection Regulation (GDPR)

For purposes of the EU’s General Data Protection Regulation (GDPR), the data controller is Barges Technologies, Inc., with an office at 7 World Trade Center, 10th floor, New York, NY 10007 USA.

If you feel that your personal data has been processed in a way that does not meet the GDPR, you have the right to file a complaint with the relevant supervisory authority.

Children’s Privacy

To use BitWine you must be at least 18 years of age. If you are under 18 years of age, please do not use our Site or Services.

Notification in the event of a Data Breach

In the event of a data breach, we will notify the owners of BitWine accounts within 72 hours of the discovery of said breach.

Additional Information

Under California Civil Code sections 1798.83-1798.84, residents of the state of California are entitled to request BitWine to provide a statement or notice setting forth what categories of personal customer information BitWine shares with third parties or corporate affiliates for such third parties’ or corporate affiliates’ marketing purposes. Such notice or statement shall identify the categories of information shared and will set forth the third parties and affiliates with which such information was shared, along with their names and mailing addresses. If you are a California resident and would like a copy of this notice or statement, please submit a written request to the email address below.

In the event that all or substantially all of BitWine’s assets have been acquired, or in the event of any merger, bankruptcy or reorganization involving BitWine, all information about you and your use of our services will likely be included in the acquired or merged assets.

If you reside in the European Union or other jurisdictions with laws governing data collection, privacy, and/or use, please note that you are transferring your personal data to the United States to BitWine and that U.S. rules governing data collection, privacy, and/or use may be less restrictive. By providing your personal data to BitWine you consent to that transfer.

From time to time, BitWine may use Data for new, unanticipated uses not previously disclosed nor described in our Policy. If our information practices change regarding information previously collected, BitWine will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.

If you wish to apply to be an Advisor on BitWine’s Advisor Program, you will be required to submit certain personal information, as required. Any information supplied by or on your behalf for purposes of becoming an Advisor may be maintained by BitWine as well as third party affiliates and other third parties. BitWine may have additional privacy terms that apply to Advisors.

If you have any questions or would like further information regarding this Policy, please contact us.